New DCC compliance reminders: self-inspection, track and trace, and premises diagrams
The Department of Cannabis Control released a set of compliance reminders for cultivators, nurseries, and processors. They cover three areas worth reviewing before your next inspection: a self-inspection checklist, track and trace timelines, and keeping your premises diagram accurate. Here is what you need to know.
The self-inspection checklist
The DCC put together a checklist to help you review the conditions of your facility before a routine compliance inspection. The items represent the major areas the compliance team evaluates.
The checklist covers:
Inventory management and track and trace requirements
Premises and cultivation plan documents
Designated canopy areas
Pesticides
Water source
Power source
Light pollution
Weighing devices and weighmaster requirements
Records
Keep in mind that the checklist is not exhaustive and is not a substitute for meeting all the statutory and regulatory requirements that apply to your license type. View the breakdown of the DCC checklist.
Track and trace timelines to keep on your radar
Track and trace reporting remains one of the top cited violations, and keeping your system updated at all times is what keeps you compliant. Here are the timelines to work from.
Report immediately: if you lose access to the track and trace system for a period exceeding 72 hours, you must report it to DCC right away.
Within 24 hours, you must:
Report any significant discrepancies in inventory to DCC
Confirm and accept or reject transfer manifests
Additional 24-hour situations are listed in California Code of Regulations (CCR), title 4, section 15049.
Within three calendar days, you must:
Record receipt of plant and package tags
Correct any data errors
Record any plants destroyed during the growing period
Record the movement of any immature plant into the mature canopy area, and immediately apply the assigned individual plant tag to each plant
Apply immature plant tags to plants received from a licensed nursery
Record the harvesting of a mature plant, or any portion of a mature plant
Within 10 calendar days of receiving a new license, you must:
Complete the track and trace credentialing process
Place your first order for plant or package tags
At least once every 30 calendar days, you must:
Reconcile all on-site cannabis inventory with the information in your track and trace account
Review your authorized users and remove anyone no longer authorized to enter information in the system
Make sure your premises diagram is accurate
When DCC inspects your premises, they verify that the diagram in your license record matches your actual licensed premises. If the two do not match, you may be subject to disciplinary action.
If you are planning a change to your premises, review CCR section 15027, Modification of Premises or Operations, to determine whether the change is "material" or "substantial." Material or substantial changes require written approval from DCC before you make the change. If your change is not material or substantial, you do not need prior approval, but you are required to submit the updated diagram to DCC within three business days of completing the change.
To request a modification or submit an updated diagram, the designated responsible party (DRP) must:
For cultivation license types: submit the updated premises diagram as a science amendment using the Cultivation Licensing System (CLS) portal.
For all other license types: submit a completed Form 27, Notifications and Requests to Modify a License, along with the updated diagram, from the DRP's email address listed in the license record.
Before editing your diagram, review CCR section 15006, Premises diagram.


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